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On October 17th, President Karen Lee submitted a letter to the Administrator of the Office of Policy Development and Research expressing opposition to the creation of an Electronic Job Registry as outlined in the Notice of the Proposed Rulemaking (NPRM) for Temporary Agriculture Employment of H-2A Aliens in the United States. For a copy of the letter, click here .

Section 655.142 of the NPRM proposed the creation of a national and publicly accessible Electronic Job Registry to post employers' H-2A job orders. The registry would be created and maintained by the U.S. Department of Labor and would serve as a public repository of H-2A job orders.

In the letter President Lee notes, "NASWA does not believe there is a need to create another electronic job registry. All states effectively have an electronic job registry through their state job bank where H-2A job orders can be posted easily and a national job registry already exists which currently links nearly all state job banks through the JobCentral National Labor Exchange".

President Lee went on to say, "Integrating H-2A job orders into the JobCentral-NLX is the most cost-effective way to inform and attract U.S. workers to agriculture jobs for which H-2A workers are being recruited. It makes little sense to create an electronic job registry for state workforce agencies when one already exists".